Idaho Case Commentaries

State v. Knight: Idaho’s Reaffirmation of the Binary Choice Between Counsel and Self‑Representation and the Limits of “Shadow Counsel”

Date: Nov 29, 2025

State v. Knight: Idaho’s Reaffirmation of the Binary Choice Between Counsel and Self‑Representation and the Limits of “Shadow Counsel” I. Introduction In State v. Knight, Docket No. 52929 (Idaho Nov....

State v. Robertson and the Constitutional Limits of Treatment-Court Waivers in Probation Revocation

Date: Nov 29, 2025

State v. Robertson and the Constitutional Limits of Treatment-Court Waivers in Probation Revocation I. Introduction In State v. Robertson, 52794 (Idaho Nov. 24, 2025), the Idaho Supreme Court...

Coronado v. City of Boise: Exclusive Employee Control Over Applications for Hearings on Workers’ Compensation Benefits

Date: Nov 29, 2025

Coronado v. City of Boise: Exclusive Employee Control Over Applications for Hearings on Workers’ Compensation Benefits I. Introduction In Coronado v. City of Boise, the Idaho Supreme Court issued a...

Acorn Investments, LLC v. Elsaesser: Clarifying the Narrow Commercial-Transaction Exception to the Non‑Assignability of Legal Malpractice Claims in Idaho

Date: Nov 20, 2025

Acorn Investments, LLC v. Elsaesser: Clarifying the Narrow Commercial-Transaction Exception to the Non‑Assignability of Legal Malpractice Claims in Idaho I. Introduction The Idaho Supreme Court’s...

Primacy of Idaho’s “Just and Reasonable” Mandate Over Multi‑State Allocation Protocols: Commentary on PacifiCorp v. Idaho Public Utilities Commission

Date: Nov 20, 2025

Primacy of Idaho’s “Just and Reasonable” Mandate Over Multi‑State Allocation Protocols: Commentary on PacifiCorp v. Idaho Public Utilities Commission I. Introduction The Idaho Supreme Court’s...

Forward-Looking Loss-of-Support as the Governing Standard for Apportioning Wrongful Death Settlements Between Parents in Idaho

Date: Nov 20, 2025

Forward-Looking Loss-of-Support as the Governing Standard for Apportioning Wrongful Death Settlements Between Parents in Idaho Introduction The Idaho Supreme Court’s decision in Rossman Law Group,...

State v. Loranger: Clarifying the Invited Error Doctrine in Sentencing Appeals

Date: Nov 20, 2025

State v. Loranger: Clarifying the Invited Error Doctrine in Sentencing Appeals I. Introduction In State v. Loranger, Docket No. 53281 (Idaho Nov. 19, 2025), the Idaho Supreme Court addressed two...

"Null and Void" Plea Clauses and the Mandatory Right to Withdraw: Commentary on State v. McGarvey (Idaho 2025)

Date: Nov 20, 2025

"Null and Void" Plea Clauses and the Mandatory Right to Withdraw: Commentary on State v. McGarvey, Idaho Supreme Court (2025) I. Introduction The Idaho Supreme Court’s decision in State v. McGarvey,...

Only Claimants May Initiate Hearings on Compensation and Income Benefits under Idaho Code § 72-706: Employers Cannot File “Complaints” to Litigate an Employee’s Entitlement

Date: Nov 16, 2025

Only Claimants May Initiate Hearings on Compensation and Income Benefits under Idaho Code § 72-706: Employers Cannot File “Complaints” to Litigate an Employee’s Entitlement Introduction In Coronado...

No “Balance-Tipping” Presumption in Occupational Disease Claims: Clarified Burdens of Proof in Weeks v. Oneida County (Idaho 2025)

Date: Nov 16, 2025

No “Balance-Tipping” Presumption in Occupational Disease Claims: Clarified Burdens of Proof in Weeks v. Oneida County (Idaho 2025) Introduction In Weeks v. Oneida County, the Idaho Supreme Court...

No Six-Month Presumption Under Idaho Constitution; COVID-19 Backlog Can Establish “Good Cause” Under Idaho’s Speedy Trial Statute

Date: Nov 15, 2025

No Six-Month Presumption Under Idaho Constitution; COVID-19 Backlog Can Establish “Good Cause” Under Idaho’s Speedy Trial Statute Introduction In State v. Fierro-Garcia, the Idaho Supreme Court...

Edwards v. Lane: Idaho Supreme Court Confirms Abuse-of-Discretion Review for Trustee Removal and Strict Appellate Briefing Requirements (with Fee-Shifting for Frivolous Appeals)

Date: Oct 28, 2025

Edwards v. Lane: Abuse-of-Discretion Review Governs Trustee Removal; Appellate Waiver for Inadequate Briefing Triggers Fees Court: Idaho Supreme Court | Date: October 23, 2025 | Docket No.: 51237...

Premium-Based Injury Confers Standing, But Enforcement Is the Remedy: Idaho Supreme Court Limits Claims Arising from Illusory UIM Coverage

Date: Oct 4, 2025

Premium-Based Injury Confers Standing, But Enforcement Is the Remedy: Idaho Supreme Court Limits Claims Arising from Illusory UIM Coverage Case: Gilbert v. Progressive Northwestern Insurance Co.,...

Bypassing Batson Step One in Idaho: State v. Buck Clarifies Hernandez Mootness and Affirms Broad Trial-Court Discretion

Date: Oct 2, 2025

Bypassing Batson Step One in Idaho: State v. Buck Clarifies Hernandez Mootness and Affirms Broad Trial-Court Discretion Introduction In State v. Buck, the Idaho Supreme Court affirmed the conviction...

Master Plans Are Not Self-Executing: Idaho Supreme Court Holds Deed-Referenced Master Plans Are Relevant but Do Not Create Restrictive Covenants or Public Dedications Without Clear, Express Language

Date: Sep 11, 2025

Master Plans Are Not Self-Executing: Idaho Supreme Court Holds Deed-Referenced Master Plans Are Relevant but Do Not Create Restrictive Covenants or Public Dedications Without Clear, Express Language...

No-Modification Means No-Modification: Idaho Supreme Court Clarifies Grandfathered Lake Encroachments, Procedures, and Abatement Enforcement

Date: Sep 6, 2025

No-Modification Means No-Modification: Temporary Post‑1974 Changes Defeat Grandfathered Lake Encroachment Permits; § 58‑1306 Procedures Inapplicable; Administrative Abatement Requires Judicial...

Limiting Anderson’s First‑Filed Rule: District Courts Need Not Defer to the Industrial Commission on Idaho Code § 72‑209(3) “Willful or Unprovoked Physical Aggression” — Dominguez Partially Overruled

Date: Sep 5, 2025

Limiting Anderson’s First‑Filed Rule: District Courts Need Not Defer to the Industrial Commission on Idaho Code § 72‑209(3) “Willful or Unprovoked Physical Aggression” — Dominguez Partially Overruled...

Row v. State: Shinn Is Not a Trigger for Successive State Post‑Conviction Relief and Rule 44.2 Does Not Create a Right to Effective Post‑Conviction Counsel

Date: Sep 5, 2025

Row v. State: Shinn Is Not a Trigger for Successive State Post‑Conviction Relief and Rule 44.2 Does Not Create a Right to Effective Post‑Conviction Counsel Introduction In Row v. State, the Idaho...

Fraud Scienter Clarified and Disclosure Act Accrual Fixed at Closing: The Idaho Supreme Court’s Dual Holdings in VanRenselaar v. Batres

Date: Sep 5, 2025

Fraud Scienter Clarified and Disclosure Act Accrual Fixed at Closing: The Idaho Supreme Court’s Dual Holdings in VanRenselaar v. Batres Introduction In VanRenselaar v. Batres, the Idaho Supreme Court...

Closing a Deed‑Reserved Highway Connection Is a Compensable Taking: Idaho Supreme Court Clarifies Substantial Impairment and Deed‑as‑Contract Enforcement

Date: Sep 4, 2025

Closing a Deed‑Reserved Highway Connection Is a Compensable Taking: Idaho Supreme Court Clarifies Substantial Impairment and Deed‑as‑Contract Enforcement Introduction In Bear Crest Limited LLC v....